Here is a proposed equation seen elsewhere on FR:
Tax = (% Foreign Input - % Foreign Sales)
So, if a product is 100% produced outside the US, it gets a 100% tax if it is only sold inside the US.
Don't underestimate the ability of Government to tax. They can get very creative even without OUR help.
Just so you know, yes, it passes Constitutional muster as being both an excise tax and a tariff.
This development work is not "sold"; it becomes part of the infrastructure of a company.
You need to know what you're talking about, first.
Worth a try--at least it'd level the field a bit. India doesn't have workman's comp, lawsuit craziness--we do. Or, perhaps a tariff leveled on the finished goods. We could also try getting rid of our legislated competitive disadvantages. Either that, or tariffs.